Right to be forgotten

INFORMATION AND PROCEDURE FOR THE RIGHT TO ERASURE (DELETION OF DATA)

Erasure and Right to be Forgotten Policy Cod. PRV-INF-04-001_v01 - Rev. 06/2026

Pursuant to Art. 17 of the European Regulation EU 2016/679 (GDPR)

The company NICOLE DI STAMBAZZI ISABELLA (hereinafter "Nicole Rimini" or "Seller") recognizes and protects the right of users to obtain the erasure of their personal data processed through the e-commerce site scarpe-da-ballo.com. This policy explains in which cases it is possible to exercise the Right to be Forgotten, the procedures involved, and the specific legal limits to the total deletion of information.

1. WHAT THE RIGHT TO BE FORGOTTEN CONSISTS OF

Pursuant to Article 17 of the GDPR, the user has the right to obtain from the Data Controller the erasure of personal data concerning them without undue delay, should one of the following reasons apply:

  • The personal data are no longer necessary for the purposes for which they were collected or processed (e.g., order completed and no intention of maintaining an active account on the store).

  • The user withdraws consent on which the processing is based (e.g., unsubscribing from the newsletter or the WhatsApp Business marketing channel) and there is no other legal basis for the processing.

  • The user objects to the processing carried out for the legitimate interest of the Data Controller and there is no overriding legitimate ground for continuing the processing.

  • The personal data have been processed unlawfully.

  • The personal data must be erased for compliance with a legal obligation set forth by European Union or Italian law.

2. LEGAL LIMITS TO ERASURE (EXCEPTIONS)

The Right to be Forgotten is not absolute and encounters specific limits established by the GDPR itself (Art. 17, para. 3) and current national regulations. Nicole Rimini will not be able to proceed with the deletion of data if the processing is strictly necessary:

  • For the fulfillment of a legal obligation (Tax Retention): Pursuant to Art. 2220 of the Italian Civil Code and tax regulations regarding e-commerce, invoices, accounting receipts, sales registers, and personal data related to commercial transactions (Name, Surname, Billing Address, Tax ID/VAT number, list of goods purchased) must be mandatorily retained for a minimum period of 10 (ten) years.

  • For the establishment, exercise, or defense of legal claims: Data related to commercial disputes, contested returns (including Video Unboxing files and photographs of tampered soles or disposable seals), or open bank chargebacks will be retained until the final resolution of the pending matter and for the ordinary limitation periods, in order to protect the Seller from fraud attempts.

3. WHAT HAPPENS OPERATIONALLY IN CASE OF A REQUEST

When a user submits a formal request for the deletion of their data, Nicole Rimini will apply a "Pseudonymization and Selective Deletion" procedure within the Shopify platform and company databases:

  • Marketing and Profiling Data (Total Deletion): The email address, phone number, and pixel/cookie tracking data will be immediately and permanently deleted from newsletter mailing lists (Shopify Messaging, EcomSend, etc., systems) and from instant marketing channels (Meta Commerce Manager / WhatsApp Business).

  • Customer Account (Deletion): The user's personal account on the Site (Shopify Customer Accounts) will be irreversibly removed, preventing future access to the reserved area.

  • Order History and Tax Data (Partial Anonymization on Shopify): On the Shopify dashboard, non-tax personal data associated with the customer profile will be deleted or redacted via the native Shopify "Erase personal data" function. The numeric and product order history will remain recorded for internal statistical purposes only, in a completely anonymous form.

  • Revenue Agency Archive: Official tax documentation (paper invoices or XML files sent to the Revenue Agency's Exchange System - SDI) will remain protected and stored in the tax archive for the 10 years required by law, accessible exclusively to the Data Controller and the appointed tax consultant.

4. HOW TO SUBMIT THE REQUEST

The user may exercise their right at any time, free of charge, by sending an explicit communication containing their name, surname, and the email address associated with the purchase or registration. The request must be forwarded to:

  • Email: nicole@scarpedaballo-nicole.it

  • PEC (Certified Email): nicole94@cert.cna.it

⏳ Response Times: The Data Controller will provide formal acknowledgement of receipt and execution of the procedure (transparently specifying which data has been deleted and which has been retained due to legal obligations) within a maximum of 30 days from receipt of the request.

 

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